Important principles in the new national design guide could be undermined by the government’s expanding permitted development rules, architects have warned
The design guide was unveiled earlier this week by housing secretary Robert Jenrick and has been widely welcomed by many in the profession, with former CABE chair Paul Finch describing it as the ‘nearest thing to a National Architecture Policy, we are going to get’.
Jenrick said the guide would replace ‘unenforceable design ideas’ with a new national standard for councils that would require material consideration at planning applications and appeals.
The document sets out 10 characteristics intended to foster local character, community and be sensitive to climate change. These are: context, identity, built form, movement, nature, public spaces, uses, homes and buildings, resources and lifespan.
Richard Simmons, former chief executive of CABE and visiting lecturer at the Bartlett School of Planning, said: ‘What will be really significant is if they really, really mean that it will be a material consideration in planning decisions. First, planning committee members and development management officers will have to take note. Given that they often lack design skills, that’s a positive.’
He added that there could be benefits if the guide ensured planning inspectors took design seriously. ‘If it binds the inspectorate, it will be a great step forward,’ he said. ‘And third, local people can use it to call councils and developers to account. That’s excellent.’
Developer Jonny Anstead, co-founder of TOWN, said the guide distilled the key principles of good design. ‘I found it an upbeat read,’ he said, ‘full of decent examples of what has been done in the UK already – and, not, thankfully, a list of dos and don’ts. It operates at a well-judged level, focusing on setting principles but stopping short of telling architects how to do their jobs.’
It stops short of telling architects how to do their jobs
But while its principles have been lauded, many worry that it will be undercut by the government’s decision to extend permitted development rights (PDR).
In his speech, Jenrick announced plans to allow homeowners to build two-storey extensions without planning permission in a rollout of PDR first suggested last year. The new rights will initially be given to blocks of flats before being extended to all detached homes.
Earlier in the week, RIBA president Alan Jones took the first swipe saying that the guidance was compromised by the ever-widening permitted development rules, which ‘would only lead to more homes that sidestep vital quality and environmental standards’.
His concerns were echoed by Matter Architecture director Roland Karthaus. While welcoming the fact the government was promoting good design and pulling together best practice, he felt the guide’s positive message was directly contradicted by what the government was doing elsewhere. ‘(PDR’s) very nature is to sidestep planning,’ he said.
Talking about the situation in Harlow where he is a member of a quality review panel, Karthaus said: ‘Several office blocks have been PDRd, mostly quite poorly. One has been done really appallingly – completely substandard housing put directly above a bus station. That would never get planning. But that’s the contradictory messages coming from government.’
DRMM’s Sadie Morgan, who has just launched the new The Quality of Life Foundation aimed at championing ’the very best in design and placemaking’, agreed.
Although she too was ‘really encouraged’ by the guide and the 10 principles, she said: ‘There is a discord between the design code and new rules for permitted development that the minister brought up at the Conservative Party conference, which has been raised elsewhere, but the attempts to embed community consultation in local plans and design code are positive.
‘And these are very much part of the Quality of Life Foundation’s community-led approach. I just think the emphasis on making a forum for sticking to ‘the vernacular’ – whatever that is – is missing a trick. In terms of aesthetics, I think it’s more helpful to talk in terms of buildings that create delight, a word I am happy to see is used elsewhere in the design guide.’
Peter Stewart of Peter Stewart Consultancy was not entirely convinced by the guidance either, saying it was predominantly the ‘stuff everybody knows already’ and was a ‘bit Janet and John, like a Ladybird book of Urban Design.’
It’s like a Ladybird book of Urban Design
He also doubted whether it would resolve a key tension over what good design is: ‘The document says a scheme ‘may draw its inspiration from the site, its surroundings or a wider context [or] it may also introduce new approaches to contrast with, or complement, its context’.
‘So there remains an inherent tension between [design] that does or doesn’t fit in. That is once more left to the poor old planning officers.’
The guide was, he thought, directed more at large-scale developments than one-off houses. He added: ‘While there is good stuff here, I can’t see many actually referring to the document [when talking to the planners].’
The new guide states that local planning authorities will be expected to develop their own design codes or guides based on the national design code. Local design guides are prepared by local planning authorities and neighbourhood planning groups to set out general principles for development, while design codes provide specific, illustrated requirements for the physical development of a site.
‘Specific, detailed and measurable criteria for good design are most appropriately set out at the local level,’ it says. ‘They may take the form of local authority design guides, or design guidance or design codes prepared by applicants to accompany planning applications.’
National Design Guide - examples of good developments
Commenting on the timing of the release and its potential effectiveness, Teresa Borsuk, a senior adviser at Pollard Thomas Edwards, added: ‘[The guide] is a sound piece of work aimed at planning officers, councillors, applicants and local communities. And a lot of it is not new. But what a difficult time for its launch – with everything else going on just now; climate change, affordability, targets, undersupply, Brexit…
It needs mighty teeth behind it to ensure its enforcement
‘So, will it receive the attention it requires? Will absorption into the planning system be enough? It needs mighty teeth behind it to ensure its enforcement. Let’s hope we can find them.’
The document states that a National Model Design Code will be published setting out detailed standards for key elements of successful design. It will be informed by the findings of the Building Better, Building Beautiful Commission which is due to publish its final report in December.
The national model design code will set standards which local planning authorities will be expected to take into account when developing their own design codes and guides, and when deciding on planning applications. This could include making streets tree-lined wherever possible or ensuring that developments take account of ‘local vernacular, architecture and materials’, the document said.
But Karthaus questioned whether the extra costs of requiring everywhere in the country to produce local design codes could be met. ‘It’s very well understood that planning departments are under huge resource pressures,’ he said. ‘These [local codes] are significant pieces of work and require quite a lot of expertise. They will presumably be done by consultants – multidisciplinary design consultants probably. Is there additional funding for this?’
On requiring local design codes, Anstead added: ‘I think it’s positive in principle to see local authorities being required to take more responsibility for design. In the Netherlands, urban design planning teams within local authorities play a much greater role and are much larger than in the UK. And it shows.
’The risk here, of course, is that local design codes aren’t well enough prepared, are too specific and cover too wide a geographic area. Ideally they will set the conditions for design (not the design itself) and, hopefully, lead to more housebuilders using decent architects.’
A Ministry of Housing, Communities and Local Government spokesperson said there was no new money to prepare the local design documents, saying: ‘Many local planning authorities already produce their own local design guides and codes. It is for local planning authorities to decide whether these are produced externally or in-house.’
A review of permitted development rights for conversion of buildings to residential use would report by the end of the year, the spokesperson said.
On the question of whether the document had sufficient ‘teeth’, the spokesperson said: ‘The National Design Guide was published on 1 October 2019 and is effective immediately from this date. [It] should give local authorities the confidence to refuse development of poor quality design and offer certainty to home builders so they understand what is required of them. It is up to local authorities to set the timescales for completion of their own local design guides and codes.’
Brian Waters, immediate past president of the Association of Consultant Architects and chair of the London planning forum
It is a very good and sophisticated primer on urban design in planning. Not long ago government refused to illustrate case studies for fear of retribution from owners of buildings, a hangup which has been finally and fully eliminated here.
As a piece of highly illustrated academic work, I think it is excellent and the identified projects represent a rollcall of distinguished, mainly housing, architects. Examples chosen are biased towards local vernacular and context but nevertheless offer a full range of good design – if slightly dominated by pitched roofs!
Abode, Great Kneighton by Proctor & Matthews Architects
Source: Tim Crocker
Putting this guidance into a planning context for architects however, I have reservations. It responds to the NPPF requirement of ‘high-quality buildings and places being fundamental to what planning and development should achieve’. Whether it will bridge the gap from the anodyne phrase to sophisticated assessment of design at the development management stage is another matter.
It also anticipates the future publication of a national model design code which will include factors to be considered when determining ’whether façades of buildings are sufficiently high quality, how landscaping should be approached, that new development should utilise a pattern of clear front and backs and that development should clearly take account of local vernacular, architecture and materials’.
This will eventually be further reinforced by local model design codes prepared by local authorities to take account of local character and vernacular.
However to move from the theoretical to successful practical implementation demands skilled designers to be involved both in the production of good schemes but also in their assessment in planning departments. The work of private practice is an excellent model for this and government will need to encourage and resource the employment of qualified architects and designers in planning departments to take this theoretical initiate forward successfully.
National Design Guide - examples of good developments
Richard Dudzicki, director, Richard Dudzicki Associates
I started reading the National Design Guide thinking to myself this is not a bad idea, but I quickly thought of the successful places I love; Farringdon in the 90s or Peckham now. They do not fit in the government’s ‘10 simple rules to good design’. The truth is very little good design or successful placemaking will fit in this dull, grey, pragmatic framework. It is about interventions. Predefining spaces will lead to failure; failure of design, failure of place and failure to create a society. Architecture as a profession should be calling out for more. In this profession, we read the brief, rip it up and throw it out of the window and try to come up with a new idea. Let’s have an anarchic version of the National Design Guide.